September 2021 Newsletter

“That’s the vendor’s problem.”

On several occasions, I’ve heard this sentence, or one like it, when talking with providers and health plans about their strategies to meet the interoperability and information blocking imperatives. In an information sharing economy, however, this assumption is very risky as it assumes everything is technological. It's not. Process and education are also major components of successful interoperability.

Information sharing is a cross enterprise process that requires organizations attend to the connections between them at least as much as they prepare their internal systems and workflows. Assembling and refining these internal systems and workflows does little, if anything, to prepare organizations to interact with third parties that participate in the end-to-end data sharing process, engage members and patients to access and use their data, enroll exchange partners in an orderly and efficient manner, and respond to disruptions in information flow that occur outside their four walls.

Information sharing is a means to multiple ends. Achieving the requisite technical capability may demonstrate compliance with regulations in a minimum necessary fashion but the name of the game is value-based care. Combining clinical and administrative data enables better contracts, improved and less costly healthcare for patients and members, and a greatly simplified health care experience for the consumer.

Information sharing requires standardizing data and putting it in the right place. Few healthcare organizations are prepared to share information, despite their investments in new technologies and consulting services to implement them. Clinical data must conform to specific vocabularies (SNOMED, LOINC, RxNorm, and others) before it can be shared. The billing diagnostic and procedure codes (ICD-10 and CPT) are used occasionally, but sparingly. These correct clinical codes must also be placed in the fields where they can be found in the electronic health record and not buried in free text fields and notes.

At MHDC, we are working with members of our Data Governance Collaborative and educating our community in the importance of attending to these essential elements of information sharing that fall outside the organization’s direct control. While some health plans and providers have the deep pockets to invest in new technologies and services that improve their internal information management, others do not. Those organizations that take a holistic view of information sharing may spend a good deal less and be further ahead in the months and years to come.

Denny Brennan, Executive Director

Please let us know what you think of our newsletter at and look for our next issue. Thank you for your continued support and participation!

MHDC Events

Meetings this month:

  • CIO Forum: September 8, 8-10am
  • DGC Deep Dive on Eye Care: September 15, 11am-12:30pm
  • DGC Steering Committee: September 15, 3-4:30pm
  • DGC Working Group: September 1, 22, 29, 11am-12:30pm
  • NEHEN Business Users Group: September 2, 9-10am
  • Spotlight Users Group: September 29, 2-3pm
  • Webinar: HealthDataViz: September 14, 10am-noon
  • Webinar: The CARIN Alliance: September 30, 11-12:30pm

Want to learn more about any of these meetings? Email

MHDC Webinars

Join us for exclusive interviews with some of healthcare’s most recognized leaders as they reveal how and why they chose their careers, what they learned on their journey, and how to apply these insights to the everchanging future of healthcare.

Our next Vantage Point Series interview features Alexandra Drane on October 5th from noon-1pm.

Missed our previous Vantage Point Series interviews? You can find recordings here.

The Vantage Point Series

Join us for exclusive interviews with some of healthcare’s most recognized leaders as they reveal how and why they chose their careers, what they learned on their journey, and how to apply these insights to the everchanging future of healthcare.

Our next Vantage Point Series interview features Alexandra Drane on October 5th from noon-1pm.

Missed our previous Vantage Point Series interviews? You can find recordings here.

Spotlight Analytics Update

Spotlight Business Analytics helps healthcare organizations run custom analytics on health data including market share, patient origin, disease prevalence, cost of care, and comparative costs and outcomes for acute care hospitals.

We are working on some big enhancements to Spotlight that include incorporating new datasets. We have a big announcement and will have more information on this at our next Spotlight User Group Meeting on September 29. Please join us - register here to get the login details. Meanwhile, we're planning to hold meetings with current Spotlight users to discuss how these changes can help and meet the different needs and objectives of each user.

The current data status is:

Loaded & available for use:

  • Massachusetts Hospital Inpatient Discharge Data FY19
  • Rhode Island Hospital Inpatient Discharge Data FY19
  • Massachusetts Emergency Department Discharges FY19

Received & ready for use soon:

  • Rhode Island Hospital Inpatient Discharge Data FY20

Future planned data:

  • Massachusetts Observation FY19
  • Massachusetts Hospital Inpatient Discharge Data FY20
  • Massachusetts Emergency Department Discharges FY20
  • Massachusetts Observation FY20
  • New Hampshire Facility Discharge Data Sets (Application pending)
  • Maine Hospital Inpatient and Outpatient Data (Application pending)

Please feel free to drop us a line with any questions or comments at In the meantime, thank you for being a Spotlight Analytics user and a member of this community! Feel free to visit our Spotlight Business Analytics page or email us at the address above for more information.

DGC Update

The Data Governance Collaborative (DGC) at MHDC is a collection of payers and providers throughout the region exploring ways to better exchange health-related data incorporating industry standards and automation as much as possible.

The DGC expects to move to the implementation phase of the code mapping service soon. This system will be available to anyone (with a discounted rate for DGC members).

We held the first in a series of Deep Dives on social determinants of health on August 5th and learned a lot about current practices and policies around SDOH needs identification and programs to meet them. We plan to continue this series in a few months but our next Deep Dive will cover eye care. Please join us on September 15 from 11am-12:30pm (in place of our standard working group meeting that week) to discuss eye care workflows and related data and interoperability issues including things like the different places and types of providers for eye care, the multitude of ways eye care is covered or paid for, testing, quality measures, diabetes-specific concerns, testing, glasses and contact prescriptions and fulfillment and more. You can register here.

Membership in the DGC is open to any payer or provider with business in Massachusetts - big or small, general or specialist, traditional or alternative. Want to know more? Email

NEHEN Update

NEHEN reduces administrative burden through the adoption of standardized transactions. It is a cornerstone service for payer and provider trading partners wishing to exchange industry standard X12, HIPAA compliant transactions in a real-time, integrated manner using APIs. Because of our unique governance, non-profit status, and membership-based model, NEHEN is able to offer very competitively priced services relative to the market.

NEHEN is in the process of presenting an advanced roadmap development plan put into motion by TriZetto Provider Solutions (TPS) and funded by a 20 million dollar, two year investment by TPS's parent company Cognizant, Inc. At the September Business Users Meeting we will present claims management developments completing the three part presentation. Previous presentations covered patient engagement and denials and contract management.

Several key features of this multi-part plan offering our members new benefits and features include PRE (Patient Responsibility Estimator) which will assist providers in meeting the requirements of the No Surprises Act federal requirements, claims attachments using the X12 275 standard, Medicare CSI (Claim Status Inquiry) and predictive claim outcomes using AI. Many other new features will also be available.

For information about NEHEN please contact us at

Electronic Prior Authorization Initiative 

This project is a prototype implementation that automates prior authorization transactions using the industry standard, open platform methods developed by the HL7 DaVinci Prior Authorization workgroup. This project will be compliant with the three related implementation guides which utilize open, FHIR based API exchange methods. This will allow each payer and each provider to implement a single prior authorization process and format for exchange so long as all of their exchange partners adhere to the same standards.

Although the progress on this initiative has been slower than initially anticipated, we are close to having signed participation agreements with the participants. Once this happens we should be able to move more quickly going forward. As this process has moved foward we have continued our participation in the DaVinci Prior Authorization workgroup activities including assisting with the creation and refinement of the evolving standards and methods for ePA and development of a new version of the implementation guide planned for 2022 to ensure we retain alignment with industry standards.

CMS has not provided updates on the release of the Burden Reduction Prior Authorization rules (which match the process used by this project as well as providing updates to other interoperability requirements). We hope that a new proposed final rule will be released by the end of this year but that is not clear at this point. Watch this space for more information.

For more information email us at

Industry Events

Interested in webinars and online conferences through September? Here are some we recommend (they're free unless otherwise noted):

We do periodically post webinars we plan to attend on social media, so feel free to follow us on Twitter (@mahealthdata) and LinkedIn for more webinar ideas and for our take on interoperability, data, health equity, telehealth, APIs, and other topics of interest.

Have an upcoming event next month to suggest? Write us at - no self-promotion please.

What is a Social Determinant of Health? 

We all have a tendency to toss terminology around like everyone knows what it means and has a consistent, standard definition for what it encompasses. As new areas with new terminology emerge it's not that easy. Social determinants of health or SDOH is one of those developing areas where there's a lot of confusion and inconsistency. If you ask five people what it means you'll get ten answers. Toss in that any real conversation about related areas or how to address SDOH has to include observable indicators, direct causes, indirect causes, and areas that are already classified as other things (like demographics) and it really gets confusing. Then consider that attempts to address SDOH involve conversations about health equity, non-traditional care pathways, integration with social services, payment models, disability, privacy and consent, and even politics and things really get sticky. Having a clear definition for SDOH that everyone agrees upon that can then be acted upon is not easy.

So what is a social determinant of health? Ask us and we can come up with at least ten definitions, but what does the industry say about it? Here are some examples:

The Healthy People 2030 program at the Office of Disease Prevention and Health Promotion at HHS publishes the following definition:

"Social determinants of health are the conditions in the environments where people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks."

The World Health Organization (WHO) uses this definition:

"The social determinants of health are the non-medical factors that influence health outcomes. They are the conditions in which people are born, grow, work, live, and age, and the wider set of forces and systems shaping the conditions of daily life. These forces and systems include economic policies and systems, development agendas, social norms, social policies and political systems."

Some organizations working in the SDOH space don't bother trying to define SDOH. HL7 FHIR Accelerator The Gravity Project doesn't provide a general definition. Rather, it defines individual social domains to explore in detail one at a time. Conversations bring in all sorts of factors, only some of which appear to fall into the general sense of the definitions above.

That said, these definitions, when they exist, are similar. However, when you dig deeper on the SDOH sections of each organization's website things get a bit murky. The Gravity Project works on social domains that are, at best, loosely associated with the general definitions and have large individual components (like disability, stress, and social connection). The WHO specifically talks about discrimination as a SDOH, bringing in all sorts of potential causes. So is the SDOH discrimination or is it the underlying identifier or condition that people are discriminating against? Is it all of the above?

At this point, you may be wondering why we care. That's simple. Most people agree that addressing SDOH is important to improving healthcare and particularly health outcomes for individuals affected by one or more SDOH. In order to do that we need data - data to identify people who have needs in this area, data to identify services available, data to track outcomes, and all sorts of other data. Useful data is standardized data with consistent format and meaning for all who use it. The first step in achieving this is defining what that data is. Then we can figure out how to collect it, exchange it, and use it in fruitful ways.

What does that mean? Is the social determinant of health transportation insecurity or is it the disability driving the transportation issues faced by a patient? Is it food insecurity or the lack of affordable grocery stores near where someone lives or the lack of funds needed to purchase food or the lack of employment to generate those funds? Is it housing insecurity or the spousal abuse causing someone to move around constantly? Does it even matter when we likely need to know all of the above (and a lot more) in order to reasonably attempt to address the actual issues faced by actual people experiencing difficulties?

As the Data Governance Collaborative starts to wrestle with these and similar questions we keep returning to the question "what is a social determinant of health?". Another area that's causing some consternation is the overlap between SDOH and other types of data. When you dig even a little bit, the cause of some of these larger issues often includes a demographic component - race, ethnicity, religion, gender, gender identity, and disability are just a few (is disability demographic data? That's another can of worms for another article). Many of these same factors are essential data for health equity work, another area that's often grouped into SDOH discussions adding to the confusion, and further complicating things is a lack of clarity around the boundaries between the two (it's not entirely clear such boundaries actually exist in any definitive way). Do we look at these as part of SDOH data as well as their other classifications or are they separate items that may have some impact?

We keep coming back to the question does it even matter? Our current answer is both yes and no. Having a workable definition for SDOH is important because the human brain requires some boundaries and constraints to think about ideas in constructive ways, so not having a clear definition is a barrier to doing the work. That said, if we use structured data for things then do we care if we capture something because it's a demographic or a SDOH or something else entirely? Maybe and maybe not. The problem is that so much of our data isn't structured, and so much of our current structured data doesn't use consistent, standard definitions. USCDI v2 requires the exchange of SDOH goals, assessments, problems, and interventions. It does not define these elements any further. Thus, defining these elements is part of the work to be done in implementing data specifications and exchange partnerships.

In order to do that, we have to understand the types of issues encountered by people that affect their health both in and out of the medical arena as well as how to start addressing them. The DGC is holding a series of Deep Dives to explore this with the wider world, but in our internal discussions one of our key questions remains "what is a social determinant of health?" As you can see, this isn't a straightforward question and we're still trying to figure out a good answer. We welcome your input. What do you think? Let us know at

Hispanic Heritage Month

September 15th to October 15 is National Hispanic Heritage Month which celebrates and honors the many cultural contributions and achievements of Hispanics and Latino Americans. What originally began as Hispanic Heritage Week back in 1968 under President Lyndon Johnson was expanded to a month two decades later by President Reagan. There are many ways to celebrate; here are a few links to get you started:

You can also find more on social media using #HispanicHeritageMonth

Wrapping Up

Before we go, here's a reminder of upcoming data exchange deadlines from ONC and CMS (including the CMS rule that's currently frozen, as noted by *):

And that's it, folks. Loved it? Hated it? Have an idea for next time? Send us feedback and suggestions about this newsletter at or send us feedback and suggestions about anything else at

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